Text

Requalification Program Evaluation Rept 50-410/90-16OL on 900430-0504.Exam Results:All Crews Performed Satisfactorily on Simulator Portion of Exam.Six Senior Reactor & Nine Reactor Operators Passed All Portions of Exam
	ML17056A871
Person / Time
Site:	Nine Mile Point
Issue date:	05/30/1990
From:	Conte R, Pullani S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML17056A870	List: ML17056A869; ML17056A871;
References
	50-410-90-16OL, NUDOCS 9006060044
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NY 3i l990

U.

S.

NUCLEAR REGULATORY COMMISSION

REGION I

Combined Report

No

~

Facility Docket No.:

Facility License

No.

Licensee:

Facility:

Examination Dates:

NRC Examiners:

Chief Examiner:

90-16

(OL)

50-410

NPF-14

Niagara

Mohawk Power Corporation

301 Plainfield Road

Syracuse,

New York

13212

Nine Mile Point Nuclear Station,

Unit 2

April 30 - May 4,

1990

S. Pullani, Senior Operations

Engineer

J . Williams, Senior Operations

Engineer

PE Bonnett, Operations

Engineer

G. Buckley, Examiner,

PNL

L. Larson

aminer,

PNL

S. Pullani,

Operations

Engineer

Date

Approved By:

ichard

.

onte, Chief,

BWR Section

Operations

Branch,

DRS

Summary:

See

Executive

Summary

5 m po

ate

EXECUTIVE SUMMARY

Written and operating

examinations

were administered

to three

crews c'onsisting

of nine Reactor Operators

(ROs)

and six Senior Reactor Operators

(SROs).

The

examinations

were graded concurrently

by the

NRC and the facility training

staff.

The results of the

NRC and the facility grading were identical.

All of

the

ROs and all of the

SROs

examined

passed all portions of the examination.

All three

crews that were evaluated

performed satisfactorily

on the simulator

portion of the examinations.

During this examination

process,

the

NRC team also

reviewed the implementation

of Niagara

Mohawk's corrective actions to address

the deficiencies identified

during the July

1989 requalification examination

which resulted

in an unsatis-

factory requalification

program evaluation.

These corrective actions

are

documented

in the Requalification

Program Action Plan attached

to Niagara

Mohawk's letter dated January

10,

1990.

The team concluded that the corrective

actions

were essentially

complete

and generally effective

and that

a signifi-

cant

improvement in the requalification program was evident.

To return the

program to

a satisfactory

status,

Niagara

Mohawk must complete all short term

corrective actions

and certify that all program deficiencies

have

been

addressed.

The examination

team also

made

an assessment

regarding

Niagara

Mohawk's Restart

Action Plan

(RAP) Underlying Root Causes

2 (Problem Solving) and

4 (Standards

of Performance/Self-Assessment.

A significant improvement in these

areas

was

noted.

This report (Section

9) also documents

a violation identified by Niagara

Mohawk

in its letter dated

February

21,

1990,

involving medical

examinations

of

licensed operators.

In reviewing this matter,

the

NRC staff has determined

that issuing

a Notice of Violation is not appropriate.

The staff has

chosen

to

exercise this discretion

because

the violation meets all of the criteria of

Appendix

C of 10 CFR Part 2, Section

G, for a licensee identified violation.

DETAILS

1.

Introducti on

During the examination period,

the

NRC administered requalification exami-

nations

to

15 licensed operators

(9

ROs

and

6 SROs).

Ten of the

15 oper-

ators belong to two regular plant operating shifts crews (five per shift)

and the remaining five belong to one licensed staff crew.

The

15 oper-

ators were divided into 3 crews for the simulator part of the examination.

The examiners

used

the process

and criteria described

in

NUREG 1021,

"Operator Licensing Examiner Standards,"

Revision 5, section

ES-601,

"Administration of NRC Requalification

Program Evaluations."

The exami-

ners also reviewed the licensee's

procedures

for conducting

licensed

operator

training and the results of the requalification examinations

administered

by the facility.

An entrance

meeting

was held with the licensee

on April 9,

1990, at the

site.

The purpose of this meeting

was to brief the licensee

on the

requi rements of the requalification

program evaluation

and to outline

a

prospective

schedule

for the examination.

The licensee

personnel

contacted

during the examination

are listed in Attachment

1.

The members

of the combined NRC/facility examination

team,

and the facility evaluator s

are also identified in Attachment

1.

2.

Examination Results

2. 1

Individual Examination Results

The following is

a

summary of the individual examination results:

RO

SRO

TOTAL

NRC Grading

Written

Simulator

Walk-Through

Overall

9/0

6/0

15/0

Pass/Fail

RO

SRO

TOTAL

Facility Grading

Written

Simulator

Walk-Through

Overall

9/0

6/0

15/0

Pass/Fail

2.2

Generic Stren ths and Weaknesses

The following is

a

summary of generic strengths

and weaknesses

noted

by the

NRC from the preparation,

administration,,and

grading of the

requalification examinations.

This information is being provided to

aid the licensee

in upgrading the requalification training program.

No licensee

response

is required.

2.2.1

0 erator Stren ths

and Weaknesses

~Siren ths:

~

Teamwork

among the crews

has

improved.

A chain-of-command,

accountability,

and improved communications

has

helped

organize

and co-ordinate

crew actions.

~

Communication skills have

improved since the previous

examination.

Formal repeat

backs,

acknowledgement

of

reports/directions

and

use of precise

language

resulted

in

a professional

atmosphere

in the control

room.

~

Station Shift Supervisor (SSS)/Assistant

Station Shift

Supervisor

(ASSS) direction and control of the shift

provided the operators

a sense of priority and account-

ability for their responsibilities

and those of the other

operators.

~

The crew'

ability to identify and evaluate

plant condi-

tions enabled

them to mitigate the effects of the event or

failure on the plant.

This included timely response

to

alarms

and awareness

of changing plant parameters

that

occurred prior to the alarm annunciating.

~

The operators

used

procedures

when appropriate,

and went

back to check the procedure if a task was performed without

a procedure

in hand.

~

The operators

displayed

a detailed

knowledge of the control

room panels.

~

Overall,

performance

of the Job Performance

Measures

(JPMs),

both in plant and simulator,

was considered

a

strength.

Weaknesses:

~

Although- communication skills have

improved, there are

still a few weaknesses,

The operators

did not always

speak

loudly enough to ensure all operators

in the control

room

were aware of changes

occurring in the plant.

During

emergencies,

all of the operators

were not always kept

abreast

of trends

and changes

in plant parameters

concern-

ing the reactor

and containment.

~

The

SSS/ASSS

did not always ensure that the entire crew was

aware of equipment that was declared

inoperable;

when the

classification of an emergency

event

had occurred

and the

reason for it; and when reentry into the

EOPs

had taken

place.

~

Ouring emergencies,

role identification was not consistent

among the various

crews

examined.

Even though the work was

completed

in a timely manner,

there

was

some confusion of

who should perform

a specific duty.

2.2.2

Pro

ram Stren ths

and Weaknesses

~Stnen

the

~

Clear

and consistent briefings

and instructions

by evalu-

, ators were considered

strengths.

~

The facility examines requalification candidates

on

Licensee

Event Report

( LER) based training.

~

The facility training personnel

were very receptive

and

responsive

to examination

comments.

~

The facility personnel

were very responsive

to requests

for

additional

reference materials.

~

The facility Simulator Instructor was very knowledgeable

and versatile with the simulator as well as plant

knowledge.

Written examination

questions

were applicable to an open

reference

examination with few exceptions.

Time validation of the written examinations

was accurate.

e

Weaknesses:

~

Specific weaknesses

with JPMs were identified:

There were

no questions

unique to

SRO levels

It was not apparent that JPMs

and questions

had

been

given

a thorough review by the facility.

This conclu-

sion is based

upon

NRC identification of expected

vs.

given answers,

typographical,

and spelling errors.

Weaknesses

identified in the performance of the

JPMs were

not generally probed

by additional questioning.

The method for identifying and obtaining procedures

at the

start of JPM was not clearly defined

and therefore

not always

consistent.

Examination questions

related to

LERs were not identified

as

such.

One of the Section

A scenarios

had to be substituted

with one of the alternate

scenarios

due to the similarity

(of topics covered) with the other scenario

selected

for

the exam.

There were

some multiple choice questions with no stem

other than

a system category

and choices that were

4

unrelated true/false

statements.

There were

some instances

of distractors

for multiple

choice questions

being obviously incorrect.

Several

short answer questions

had more than

one correct

answer;

the

stem of the question did not contain sufficient

discriminating information.

This weakness

was also identified by the Instructional

Technologist

Group (of the Niagara

Mohawk Training Depart-

ment)

and

had been

addressed

by the facility (see Section

7.2 of this report for further details).

The written examination

questions

were supplied without a

reference

to learning objectives.

The process

of assigning

learning objectives

to

examination

questions is in progress

as part of the

Systems

Approach to Training (SAT) Program.

The written examination

questions

were supplied with only

a K/A value

and not with the K/A number from NUREG 1123.

The facility supplied

a cross

reference

during the onsite

preparation

week which matrixes the facility task number to

the applicable

K/A number.

Incorrect facility task

numbers

were assigned

to

some

questions.

There were

some instances

of questions written on tasks

which were not applicable to the license

held or with

little safety significance'

Note:

The facility resolved

most of the above weaknesses

for

the current examination questions.

To address

these

weaknesses

for the requalification examination

question

bank,

the facility

plans to review the entire bank by October 31,

1990.

3.

Re uglification Pro

ram Evaluation Results

The facility program for licensed operator requalification training met

all criteria established

in ES-601,

"Administration of

NRC

Requalification

Program Evaluation."

Note:

The examination results for the individual who had failed two

and was retested

during this

examination

were not used in the evaluation of the facility

requalification program.

The criteria in ES-601 are:

a.

Ninety percent pass/fail

decision

agreement

between

the

NRC and the

facility grading the written and operating

examinations.

There

was

100Fo agreement

on this criterion.

b.

At least

75/. of all operators

pass

the examination;

not including

individuals selected

who had previously passed

the examination.

NRC grading is the only consideration

for this criterion.

There were

no individuals selected

who had previously passed

the examination.

All operators

(100/) passed

the examination.

c.

There shall

be

no more than

one crew failure during the simulator

portion of the operating

examination,

although the failure of one

crew

MAY cause

the program to be considered

unsatisfactory.

NRC grading is the only consideration

for this criterion.

Three

crews were evaluated

and all three

crews

passed

the simulator portion

of the operating examination.

d.

The program meets

the requirements

of 10 CFR 55.59 (c)(2), (3) and

(4), or is based

on systems

approach

to training.

The review of the licensee's

procedures

for conduct of licensed

operator training indicated that the requalification program meets

the requirements

of 10 CFR 55.59(c)(2), (3),

and (4) for lectures,

on-the-job training,

and evaluations.

In addition,

ES-601 contains criteria that may contribute to a program

being determined unsatisfactory.

None of these criteria were applicable.

4.

Re uglification Examination

Pre aration

The licensee

submitted

reference materials,

test items,

and

a Sampling

plan approximately

60 days before

the examinations

were administered.

These materials

were reviewed in the Regional Office and the specific

test

items proposed

by the facility were reviewed on-site

by the combined

NRC/facility examination

team.

The facility then revised

the items

and

produced

the examination that was administered

to the examinees.

The test

items that were administered

to the operators

are listed in Attachment

2.

The NRC-facility examination

team

spent

a considerable

amount of time in

improving the quality of the simulator scenarios

proposed for the examina-

tion.

Some of unnecessary

operator action evaluation

steps

and Individual

Simulator Critical Task ( ISCT) steps

were deleted

from the scenarios.

The

ISCTs were reviewed against

the "four-fold criteria" in the proposed

ES-601,

Revision

6,

as additional

guidance.

The team's effort in this

area

helped

in identifying valid ISCTs for the examination.

Only minor revisions

were required to the JPMs proposed for the examina-

tion.

The JPMs were generally of good quality.

However,

several

JPN

questions

had to be replaced

because

they were simple "look up" types for

which answers

would be found easily by reading the related procedural

precautions

or steps.

The Sampling

Plan submitted for the examination

was adequate

for the

'urpose.

The plan indicated the emphasis

that each topic received during

the most recent requalification cycle and included

a

summary of the

specific examination

subject requirements.

The written examination questions

submitted for NRC review were generally

satisfactory.

However,

the quality of the questions

could be further

improved

as indicated

by several

weaknesses

identified by the

NRC.

t

F

The facility has

a general

task listing with each task having assigned

a

specific K/A and value.

When

a specific task question

(as

opposed to

a

general

task) is written, the K/A and value assigned

to the general

task

is transferred

to the specific task,

In most instances

the specific tasks

are of a lower safety

importance

than the general

task and the assigned

K/A and value are not applicable.

In fact, there

were several

questions

when compared with the specific item in

NUREG 1123 which did not meet the

3.00 K/A value cut-off criteria for the requalification examinations.

However, the questions

were retained

in the examination to meet the

sampling plan.

guality control

was adequate

for the examination materials that were

submitted to the

NRC following the review by the combined NRC/facility

examination

team.

The facility had

a week to make changes

and review the

corrected materials prior to submittal to the

NRC for final review.

The

examination materials that 'were submitted contained

the specific test

items

and the required revisions that

had been

agreed

upon by the

examination

team.

'j

Refer to Section 2.2.2 for strengths

and weaknesses

identified during the

preparation of the examinations.

5.

Re uglification Examination Administration

The dedication of the facility training personnel

during the extensive

hours that were required for administration of the examinations

was

a

strength of the program.

The stress

of the long hours did not affect the

quality of the evaluations.

Training and operations

personnel

were very

cooperative

throughout the examination

process.

Administration of the examinations

was generally satisfactory.

Time

validation of the static simulator and open reference

examinations

appeared

satisfactory.

The simulator portion of the examination

was conducted

smoothly

and

efficiently.

The scenarios

required minimal setup

time and the simulator

operator did not allow any delays to occur during performance of the

scenarios.

The time of introduction of malfunctions

by the simulator

operator during scenario

was sufficiently flexible and coordinated

by one

facility evaluator to allow all evaluators

to complete all required

evaluations.

The team assessed

the simulator's capabilities

as limited.

The limited

number of malfunctions,

the high dependence

on instructor overrides

( IOs),

and limited number of prepared

scenarios

restricts

the flexibilityof

training and evaluation.

Specific items related

the simulator fidelity

were discussed

with the simulator instructors.

The facility representa-

tives informed the

team that

many

new simulator enhancements

are being

added,

and

a program to write additional

scenarios

has

been established.

The simulator performed well during the examination,

in that there

were

no

delays

due to simulator

down time

The logistics of the walk-through examinations

(JPMs) went smoothly.

The

time validation of the JPMs was reasonably

accurate,

but could be improved

using the data collected during administration of the examination.

Refer to Section 2.2.2 for strengths

and weaknesses

identified'during the

administration of the examination.

6.

Examination Gradin

and Anal sis of Results

Crew performance

on the simulator portion of the examination

was critiqued

by the lead facility examiner

immediately following completion of both

scenarios.

These critiques were satisfactory

and included input from the

licensed operators.

The

NRC and the facility evaluations

discussed

the

results of the'imulator examination

and the followup questions

to be

asked

the examinees

following each individual scenario.

In the majority

of instances,

the

NRC and the facility evaluators

agreed

on all the areas

that were evaluated.

Follow-up questions

were asked

as necessary

to

clarify operator actions.

10

The results of the individual JPMs were discussed

immediately following

administration of the walk-through examinations.

The

NRC and the facility

evaluators

did not agree

on the evaluation of an individual JPM in two

cases

and

an individual

JPM question

in four cases,

but the facility was

more conservative.

A summary of facility grading

on all parts of the examination is included

in Attachment

4 to this report.

Comparison of the

NRC grading

and the

facility gr'ading indicated general

agreement

between

the two.

In general,

the facility grading

was found to be more conservative.

7.

Follow-u

on Previousl

Identified

Re uglification Pro

ram Deficiencies

and Corrective Actions

As

a result of the requalification examination

conducted during the weeks

of July

17 and July 24,

1989,

weaknesses

in the individual operator

performance

and the Nine Mile Point

2 requalification

program were identi-

fied.

The results of the examination

and the weaknesses

were documented

in the examination report 50-410/89-12(OL).

The program was determined to

be unsatisfactory.

Based

on that evaluation,

Nine Mile Point Unit 2

implemented

a Requalification

Program Action Plan to correct

these defi-

ciencies.

The latest revision of the Requalification

Program Action Plan

(Revision 2) was attached

to Niagara

Mohawk's letter

NMP2L 12223 to the

NRC, dated January

10;

1990.

During the week of April 9,

1990,

the

NRC staff reviewed the corrective

actions

implemented

by Niagara

Mohawk to address

the specific issues

addressed

by the Requalification

Program Action Plan.

The results of this

review are

summarized

below.

7. 1

Unsatisfactor

Re uglification Pro

ram

Niagara

Mohawk's corrective actions

in this area listed in the Requal-

ification Program Action Plan are essentially

complete.

The only

corrective action in this area which was

open at the time of this

review was Item

1.BE 10.

This item was subsequently

closed

on April

24,

1990.

This item is related

a follow-up assessment

of the Unit 2

Requalification

program by an Independent

Assessment

Team (IAT).

At

the time of the initial NRC review, the

IAT had just completed their

assessment

and concluded that the Requalification

Program Action Plan

is being implemented

and the original (October 27,

1989)

recommenda-

tions by the

IAT have either been

implemented or are being addressed.

The IAT also concluded that significant improvements

in management

oversight,

operations

and training communication interface,

and

attention to detail

are

now evident,

but continued

management

atten-

tion is needed

in

some areas

to ensure that improvements

are

completed.

Based

on

NRC review of a sample of the completed correct-

ive actions

in this area,

the staff concludes

that the corrective

actions

in this area

are essentially

complete

and significant improve-

ment in the requalification

program is evident.

The observations

by the examination

team in the course of preparation

and conduct of the requalification examination

administered

during

the week of April 30,

1990 support the above conclusion.

Based

on

this evaluation,

Niagara

Mohawk's corrective actions

on this issue

are considered

satisfactory.

7.2

Mritten Examination Structure

Four corrective actions

were identified to satisfy the concerns with

the

1989 written requalification examinations.

These

concerns

were:

1

~

. Test item construction

was not clears

2.

Point values for multiple part answers

were not specified.

3.

Several

double jeopardy questions

were noted

4.

guestions

requiring multiple responses

were not separated

out.

The facility has formally closed out all four of the corrective

actions.

The

NRC'

review of the corrective

action files indicates

that the corrective actions

have

been

completed.

However,

the

NRC's

review of the April 1990 requalification written examinations indi-

cates that

some double jeopardy questions

( Item 3 above)

do exist in

the examination question

bank.

The facility plans to review all bank

questions

by October 31,

1990.

Niagara

Mohawk's corrective actions

and plans to re-review the

exam

bank are considered

satisfactory.

7.3

0 erator

Knowled e Deficiencies

The licensee's

evaluation of the

1989 written examination, raised

concerns

about operator

knowledge deficiencies.

Six corrective

actions

were established

to correct those deficiencies.

The correct-

ive actions for this issue

included:

review of the written examination

results for weaknesses

in the requalification training program,

and

development

and implementation of a remediation

plan.

All corrective actions for this issue

were complete

and found to be

satisfactory

except for corrective action item 3.B.4.6 in the Requal-

ification Program Action Plan.

One licensed operator

had not

completed

the

EOP training required

by this corrective action.

The

NMP-2 training department

planned to train the

one remaining indivi-

dual

by the

end of May 1990.

Successful

completion of training by

the remaining individual will close this issue.

12

completed training in verbal

communications for operators

and

instructors.

Observations

of the operating

crew and training

instructors

are being

made

by the plant management

personnel

during

the simulator training sessions

for identifying and correcting weak-

nesses

in the crew and the instructor performance.

Niagara

Mohawk

has also established

a plan

and

a schedule

to continue

the required

corrective actions

on

an ongoing basis,

for preventing

the recurrence

of identified deficiencies

in this area.

A significant improvement

in verbal

communication skills was noted

during the simulator portion of the April 1990 requalification exami-

nation.

Out of the three

crews

examined,

one crew exhibited excell-

ent communication skills, whereas

performance of the other two crews

was average

and could be further improved.

The corrective actions

in this area which were not fully complete at

the time this inspection

were Items 4.8.3, 4.8.4,

and 4.8.5 involving

crew communications.

Niagara

Mohawk plans to complete

and close out

these

items

by May 14,

1990.

Subject to completion of these

items,

Niagara

Mohawk's corrective actions

on this issue

are considered

satisfactory.

7.5

STA Involvement in Plant Assessment

and Event Control

This issue

deals with clarifying STA responsibilities

(a collateral

reponsibi lity of Assistant Station Shift Superintendent)

during

emergencies

and providing training in this area.

The

STA responsi-

bilities are described

in N2-PDI-1.08, "Operations Policy for Emer-

gency Procedures,"

Revision 3, dated

October

1989.

STAs and instruc-

tors

have

been trained

on these responsibilities.

A program

has

been

established

by the licensee,

and is ongoing, for management

observa-

tion of simulator training.

The

NRC team reviewed the supporting

documentation

and discussed

these activities with Niagara

Mohawk's

personnel.

In addition,

the performance of the

STA in the simulator

during the April 1990 requalification examinations

was observed,

to

identify any weaknesses

associated

with this issue.

No concerns

were

identified.

The Niagara

Mohawk actions

on this issue

are considered

satisfactory.

7.6

0 erator Actions for EOPs

The specific issue

was that operator actions

were not always in

accordance

with the guidance

provided in the

Emergency

Operating

Procedures

(EOPs),

The corrective actions

were reviewed

by the

NRC

team.

No discrepancies

were noted.

Operational directives that establish

management

expectations

have

been

developed

and incorporated

into plant operations

and training.

Management

has also established

a formal review process

in which

management

personnel will observe

simulator training and identify

13

weaknesses

in the crews or training instructors.

The development of

lesson

plans covering Mitigation of Core

Damage is continuing

and

expected

to be completed

by the

end of the year.

The licensee's

corrective actions

on this issue

are considered

satisfactory.

7.7

0 erator

Actions for Normal 0 eratin

Procedures

This issue deals with deficiencies

in operator actions during emer-

gency events

when considering

the requirements

of normal operating

procedures.

The licensee

conducted training in the areas

where

deficiencies

were noted during

EOP refresher training.

The tasks

that operators

were expected

to perform with a procedure

were identi-

fied and training is included in the 1990/1991 Requalification

Program.

The licensee's

document

N2-001-1.09,

"EOP Users Guide,"

defines

management

expectations

for verification of immediate actions

taken during emergency conditions.

The

NRC team reviewed the support-

ing documentation

and discussed

these activities with licensde

personnel.

Also, operator

performance

on the simulator during the

April 1990 Requalification

Examination

was observed

to identify any

weakness

in immediate actions

taken

by the operator s.

No weaknesses

were noted.

This issue is considered satisfactorily resolved.

7.8

D namic Simul,ator Scenarios

The dynamic simulator scenarios

previously used

were not always

realistic,

manageable,

and of approximately

50 minute duration

as set

forth in ES-601.

The corrective actions for this issue

concerning

the quality of the dynamic simulator scenarios

were reviewed.

It was

noted that all but three of the fifteen scenarios

were

one hour in

length vice

50 minutes.

This is,

however, consistent with ES-601

guidelines.

Ten

new scenarios

were to be developed

and incorporated

into the

1990/1991 Requalification

Program.

Nine of the ten were

completed

and

scheduled

in the program.

This issue is considered

satisfactorily resolved.

7.9

Teamwork Durin

Emer enc

Events

The issue

was that teamwork,

including prioritization of crew

actions,

evaluation of plant conditions,

and communications,

was weak

during emergency

events.

The corrective actions for this issue

concerning the weakness

in teamwork, evaluation of plant conditions,

and communications

were reviewed

and the following discrepancy

was

noted.

Item 9.B.3 states

that operator

crews

and training instruct-

ors will be trained to the latest revision of Operation

Department

Instruction, concerning

verbal

communications

and

EOP usage.

This

training was completed;

however, insufficient training records

were

available to show that training was administered

to all personnel

concerned.

The training department

has

made

a commitment to retrain-

ing (by June

30,

1990) in this area to ensure all personnel

have

received this training

(48% completed

as of April 30,

1990).

I

14

Subject to the retraining of all personnel

as discussed

above

and

retention of sufficient training records,

Niagara

Mohawk's corrective

actions

on this issue

are considered

satisfactory.

7. 10 Summar

of Review

The

NRC review of Niagara

Mohawk's actions indicates that the correc-

tive actions

were essentially

complete

and generally effective,

and

that

a significant improvement

in the requalification

program

was

evident.

The

NRC review identified certain

incomplete actions

(see

Sections

7.2, 7.3, 7.4 and 7.9 of this report).

Niagara

Mohawk has

made

a

, commitment to complete

the short term actions

by July 13,

1990,

and

one long term action

by October

31,

1990.

This is an unresolved

item

pending completion of the actions

and their review by

NRC (50-410/

90-16-01).

8.

Assessment

Re ardin

RAP Underl in

Root Causes

2 and

4

Confirmatory Action Letter 88-17, dated July 24,

1988, required Niagara

Mohawk Power Corporation to perform

a root cause

analysis of why they had

not been effective in recognizing

and remedying

problems.

In addition,

Niagara

Mohawk was required

to develop

and implement

a Restart Action Plan

which documented

the underlying root causes

of their management

deficien-

cies

and their associated

corrective actions,

During the weeks of October

9 and

16,

1989,

an Integrated

Assessment

Team

Inspection

( IATI) reviewed the effectiveness

of Niagara

Mohawk's actions

toward resolving the programmatic

and technical

issues

addressed

in their

Restart Action Plan.

The IATI concluded that Niagara

Mohawk's Restart

Action Plan, with respect

to the five identified underlying root causes

was in place

and well understood

by the Nuclear Division personnel;

how-

ever,

the plan was being

implemented with varying degrees

of effectiveness

and performance.

Specifically, the IATI determined that progress

on underlying root causes

(URCs) 1,

3 and 5, (Planning

and Goal Setting, Organizational

Culture,

and

Teamwork, respectively)

showed clear improvement.

For

URCs

2 and

4

(Problem Solving and Standards

of Performance/Self-Assessment),

the IATI

concluded that progress

was slow as demonstrated

by limited improvement in

both of these

areas.

Several

team observations

indicated that while

problems

were being identifi'ed, the problems

were frequently not being

resolved.

Further,

although station personnel

were cognizant of the

new

standards

of performance,

their actions did not demonstrate

that they were

incorporating

them into their daily work activities.

During the preparation

and administration of the April 1990 requalifica-

tion examination,

the

NRC team

made the following assessment

of Niagara

Mohawk's performance

under the areas of Problem Solving (URC2) and

15

Standards

of Performance/Self-Assessment

(URC4) with respect

to its

Requalification

Program for licensed operators.

8.1

Problem Solvin

URC2

The

NRC team reviewed the implementation of corrective actions

in the

Niagara

Mohawk's Requalification

Program Action Plan for the deficien-

cies identified during the July 1989 requalification examination.

The team concluded that the corrective

actions

are essentially

complete

and generally effective

and that

a significant improvement

in the requalification program

was evident.

The team also

found that

Niagara

Mohawk has

made

a concerted effort to complete

the required

corrective actions

in a timely manner

and to track the progress

of

these

actions

using its Nuclear Commitment Tracking System

(NCTS).

8.2

Standards

of Performance/Self-Assessment

URC 4

One of the corrective actions

in the Requalification

Program Action

Plan

was to train all operators

and instructors

in verbal

communica-

.

tions during the

Emergency Operating

Procedure

(EOP) simulator

scenario training sessions.

Niagara

Mohawk has completed this

training.

A significant improvement in verbal

communication skills

was noted during the simulator portion of the April 1990 requalifi-

cation examination.

Out of the three

crews examined,

one crew

exhibited excellent communication skills, whereas

the performance of

the other

two crews

was considered

average.

Observations

of the operating

crew and training instructors

are being

made

by the plant management

personnel

during the simulator training

sessions

for identifying and correcting weaknesses

in the crew and

instructor performance.

Niagara

Mohawk has also established

a plan

and

a schedule

to continue

the observations

on an ongoing basis for

preventing

the recurrence

of identified deficiencies

in this area.

The team also noted

good procedural

adherence

by the operators

during

the performance of the simulator

and Job Performance

Measure

(JPM)

portions of the April 1990 Requalification examination.

These observations

were considered

positive indications in the areas

of self-assessment

and implementation of the standards

of perform-

ance.

9.

Follow-u

on Licensee-Identified Violation

The purpose of this section is to document

a licensee identified violation

at Nine Mile Point involving medical

examinations

of licensed operators.

Niagara

Mohawk is committed to Regulatory Guide

(RG) 1. 134,

Rev.

1 (March

1979), for meeting the requirements

needed for medical certification of

its licensed operators

(10 CFR 55).

This revision of

RG 1. 134 references

16

ANSI 546-1976,

which is essentially

identical to ANSI 3.4 - 1983.

Regul-

atory Guide 1.134

was revised in April 1987, to reference

the later ANSI

standard;

and,

since then,

Niagara

Mohawk has

used

the

new revision

as

guidance.

The licensee's

previous doctor apparently misinterpreted

the

guidelines

on the

need for laboratory testing

as

a part of the medical

examination.

The misinterpretation

resulted

in

some deficiencies

in

medical

examinations;

namely,

laboratory work was not done.

The Certi-

fication of Medical Examination

(NRC Form 396) states

that the guidance

in

ANSI 3.4-1983

was followed; and,

as

such,

a licensee

representative

certi-

fies,

by signature,

that the information

on the

Form 396 is true

and

correct.

Section

50.9 of

10 CFR Part 50 states,

in part, that information provided

to the Commission

by a licensee

shall

be complete

and accurate

in all

material

respects.

Contrary to the above,

not all medical

examinations

were complete

and accurate.

This is

a Severity

Level

IV violation.

In reviewing this matter,

the

NRC staff has determined that issuing

a

Notice of Violation (NOV) is not appropriate.

The staff has

chosen to

exercise discretion

because

the violation meets all of the criteria of

Appendix

C of 10 CFR Part 2, Section

G as discussed

below.

1.

The violation was identified by the licensee.

They discovered

the

inaccuracies

during discussions

between their physician

and the

license holders.

2.

The violation is normally classified at Severity Level

IV or V.

This

is

a Level IV.

3.

The violation was reported.

The licensee

telephoned

the Region I

office and followed this up with a letter to the Region (Attachment

5 to this report) documenting

the issues.

4.

The violation has

been corrected.

As stated in a letter. dated

March

12,

1990,

from Niagara

Mohawk to the Regional Administrator, all

licensed operators

have

been

re-examined

using the guidance of ANSI/

ANS 3.4-1983

(see Attachment

6 of this report).

It is expected that

future medical certifications will continue to be accurate.

5.

The violation was not willful nor could it have

been prevented

by

corrective action for a previous 'violation.

There are

no indications

of any deliberate falsification of documents

nor are there

any indi-

cations that the licensee

was reluctant to promptly notify the Region

once the errors

were discovered.

Furthermore,

these errors were the

result of one doctor's interpretation of the guidance.

In summary,

the

NRC staff has determined that enforcement discretion is

the correct response

to this matter

and that

no further action is

necessary.

17

10.

~Ei

I

An exit meeting

was held at the conclusion of the examinations

on

May 4,

1990.

The personnel

in attendance

are indicated in Attachment

1.

The

preliminary

NRC results of the simulator

and walk-through portions of the

examinations

were presented.

Examination preparation

and administration

were discussed

along with the results of the facility administered

exami-

nations.

Attachments:

1.

Persons

Contacted

2.

Requalification

Examination Test Items

3.

Documents

Reviewed

4.

Licensee

Results,

Licensee's

Letter to NRC, dated

May 18,

1990

5.

Licensee's

Letter to

NRC, dated

February

21,

1990

6.

Licensee's

Letter to

NRC, dated

March 12,

1990

V

jl

Attachment

1

Persons

Contacted

1.

Nia ara

Mohawk Power Cor oration

NMPC

R. Abbott, Station Superintendent

(2)

W. Bandla, Unit

1 Asst.

Supdt.

Operations

(2)

RE

Brown, Instructor

( 1), (2), (4)

G. Brownell, Nuclear Regulatory

Compliance (2)

S. Burton, Unit

1 Requalification Training (2)

G. Brownell, Nuclear Regulator

Compliance

( 1)

J.

Cobb, Facility Evaluator (2) (4)

M. Colomb, Operations

Superintendent

( 1), (2), (4)

G. Corbin, Supervisor Simulator Tech. (1), (2)

B. Hennigan,

Instructor (1), (2), (3)

J.

Kaminski, Unit

1 Operations

Training (2)

J. Pointexter,

Training Supervisor (1)

A. Rivers, Superintendent

Training Nuclear (2)

R. Seifried, Asst.

Supdt. Training ( 1) (2)

J.

Throckmorton, Facility Evaluator (2), (4)

J. Toothaker, Facility Evaluator (2), (4)

E. Townsent,

Operations,

(2) (3)

P. Walsh, Facility Evaluator (2), (4)

B. Williamson, Facility Evalvator (2), (4)

2.

Nuclear

Re viator

Commission

NRC

P: Bonnett,

Operations

Engineer

( 1), (2)

G. Buckley,

Examiner (PNL) (2)

L. Larson,

Examiner

(PNL) (2)

R.

Laura,

Resident

Inspector (2)

S. Pullani, Senior Operations

Engineer (1), (2)

J. Williams, Senior Operations

Engineer (1), (2)

Notes

(1) Attended Entrance

Meeting, April 9,

1990

(2) Attended Exit Meeting,

May 4,

1990

(3) Member,

Combined Facility/NRC Examination

Team

(4) Facility Evaluator

Attachment

2

Re uglification Examination Test Items

!

~ ~

0

~ I

j

SIMULATOR SCENARIOS

SIMULATOR EXAM 51

SCENARIO

SIMULATOR EXAM 52

02-REQ-009-1DY-2-14

02-REQ-009-1DY-2-15

SCENARIO

SIMULATOR EXAM 53

02-REQ-009-1DY-2-14

02-REQ-009-1DY-2-15

SCENARIO

02-REQ-009-1DY-2-14

02-REQ-009-1DY-2-15

JPM'S

JPM

EXAM I1

COMMON

02-REQ-SJE-264-2-44

02-REQ-SJE-200-2-55

02-REQ-SJE-200-2-10

02-REQ-PJE-262-2-66

02-REQ-PJE-296-2-74

UNCOMMOM

JPM

EXAM I2

JPM

EXAM I3

02-REQ-SJE-259-2-46

02-REQ-SJE-203-2-48

02-REQ-SJE-206-2-58

02-REQ-PJE-200-2-63

02-REQ-PJE-264-2-65

COMMON

02-REQ-SJE-264-2-44

02-REQ-SJE-200-2-55

02-REQ-SJE-200-2-10

02-REQ-PJE-262-2-66

02-REQ-PJE-296-2-74

UNCOMMON

02-REQ-SJE-261-2-38

02-REQ-SJE-201-2-40

02-REQ-SJE-200-2-53

02-REQ-PJE-296-2-83

02-REQ-PJE-200-2-69

COMMON

02-REQ-SJE-264-2-44

02-REQ-SJE-200-2-55

02-REQ-SJE-200-2-10

02-REQ-PJE-262-2-66

02-REQ-PJE-296-2-74

UNCOMMON

02-REQ-SJE-205-2-8

02-REQ-SJE-253-2-24

02-REQ-SJE-200-2-50

02-REQ-PJE-296-2-86

02-REQ-PJE-200-2-71

WRITTEN EXAM RO-1

A1 02-REQ-009-1ST-2-29

S04

S05

S06

S07

S08

S10

S11

S12

S13

A2 02-REQ-009-1ST-2-36

S03

S04

S05

S06

S07

S08

S09

S10

S11

S12

2000110501-B01

2000200501-B02

2000270501-B03

2000400501-B01

2009230501-B01

2010100101-B01

2019230101-B01

2020060101-B01

2020060101-B02

2040010101-B01

2049110101-B01

2059330101-B01

2119090401-B01

2150230101-B03

2189030401-B01

2239220101-B01

2490020101-B01

2539060401-B05

2569090401-B01

2619010101-B01

2889230101-B02

~ I

WRITTEN EXAM RO-2

A1 02-REQ-009-1ST-2-22

S04

S05

S06

S07

S08

S09

S10

B1

02-REQ-0090-1ST-2-40

S03

S04

S05

S06

S07

S08

S09

S10

2000130501-B01

2000310501-B01

2000690501-B01

2009230501-B01

2010080101-B01

2010130101-B01

2029180101-B01

2029360101-B01

2059300101-B01

2090040101-B01

2119010401-B01

2119170101-B01

2150230101-B01

2230220101-B02

2439070101-B03

2490020101-B02

2539060401-B03

2740050101-B01

2769100401-B02

2889390101-B01

2949040401-B01

2969010101-B01

VRITTEN EXAM RO-3

A1 02-REQ-009-1ST-2-30

S02

S03

S04

S05

S06

S07

S08

S09

S10

S11

A2 - 02-REQ-009-1ST-2-35

S03

S04

S05

S06

S07

S08

S09

S10

S11

S12

2000020501-B01

2000160501-B01

2000310501-B01

2000400501-B01

2000690501-B02

2009230501-B01

2020060101-B03

2059330101-B01

2059380101-B01

2089130401-B01

2110040101-B03

2119090401-B01

2150220101-B01

2189120601-B01

2230020101-B01

2399150401-B01

2549010401-B01

2760040101-B01

2850070101-B01

2889040101-B03

2949010101-B01

VRITTEN EXAM SRO-1

A1 02-REQ-009-1ST-2-29

S02

S03

S04

S06

S07

S08

S10

S11

S13

A2 02-REO-009-1ST-2-36

S01

S02

S03

S04

S06

S07

S08

S09

S11

S12

2000200501-B02

2000270501-B02

2009230501-B01

2010100101-B01

2019230101-B01

2020060101-B01

2020060101-B02

2040010101-B01

2049110101-B01

2119090401-B01

2150230101-B03

2189030401-B01

2539060401-B05

2569090401-B01

2889230101-B02

3410180303-B03

3410180303-B09

3440390303-B02

3449400603-B01

3449560603-B02

3450420503-B03

WRITTEN EXAM SRO-2

A1 02-REQ-009-1ST-2-22

S01

S03

S05

S07

S08

S09

S10

A2

02-REQ-009-1ST-2-40

S01

S02

S03

S05

S06

S07

S08

S10

2000400501-B01

2009230501-B01

2010080101-B01

2029180101-B01

2029360101-B01

2059330101-B01

2090040101-B01

2119010401-B01

2119170101-B01

2150230101-B01

2230220101-B02

2439070101-B03

2539060401-B03

2740050101-B01

2769100401-B02

2889390101-B01

2949040401-B01

2969010101-B01

3410330303-B01

3440150303-B01

3440170303-,B01

3440310303-B04

VRITTEN EXAM RO-3

A1 02-REQ-009-1ST-2-30

S01

S02

S03

S04

S05

S06

S07

S08

S09

S11

A2 02-REQ-009-1ST-2-35

S01

S02

S03

S04

S05

S06

S08

S09

S10

S12

B

2000020501-B01

2000160501-B01

2000310501-B02

2000400501-B01

2010170101-B01

2019100401-B01

2020060101-B03

2059330101-B01

2089130401-B01

2150220101-B01

2230020101-B01

2399150401-B01

2549010401-B01

2760040101-B01

2889040101-B03

3410180303-B04

3410180303-B10

3449390603-B02

3449410603-B01

3449530603-B01

3450420503-B01

Attachment

3

Documents

Reviewed

Number

NTP-11

OPS/2070

NMP-63431

OPS/2067

02-REQ-001-221-2-01

02-REQ-0009-TRA-2-01

Title

Licensed Operator Requalification Training

Biennial Schedule

90/91

Memo.

from A. Rivers to J. Willis;

March 21,

1990;

Subject:

NMP-2 Requalification Training

Cycle Status

Report through Cycle 2, 90/91

Licensed Operator Requalification Training

Cycle

C02 90/91

Schedule

(Feb.

5,

1990-

March 9,

1990)

Containment

Entry and Exit (Lesson

Plan)

Loss of Electrical

Power/Loss of SSW

(Simulator

Lesson

Plan)

Selected

training records

Revision

2

NA

Oec.

89

NA

Attachment

4

~

Licensee

Results

7 NIAGARA

u MOHAWK

NHP-67414

NINE MILE POINT NUCLEAR STATION/P.O. BOX 32 LYCOMING,NEW YORK !3093/TELEPHONE (315) 343-2110

May 18, .1990

Mr. Timothy Martin

Regional Administrator

ATTN: Mr. Robert

M. Gallo

Branch Chief

United States

Nuclear Regulatory

Commission

Region

I

475 Allendale

Road

King of Prussia,

PA

19406

Oear

Mr. Martin

Attached

are

the

Facility

grades

for

the

NRC

evaluated

Operator

Requalification

Examinations

administered

at

Niagara

Mohawk

Power

Corporation,

Nine Mile Point

Unit

2 during

the

week

oF April 30,

1990.

A

summary

of

our

results

as

compared

to the

program evaluation criteria

oF

NUREG 1021

ES-601

and

a

selF

evaluation

of

our

Licensed

Operator

Requalification

Program

are

also

included.

Please

Feel

Free

to contact

me if any

Further

information is desired.

Thank

you

For your cooperation

and the cooperation

of your stafF.

Sincerely,

~nEc'..

J.

L. Willis

General

Superintendent-Nuclear

Generation

JL'A/v'GP/kab

Attachments

cc:

S. Pullani

(USNRC)

LICENSED OPERATOR

REQUAL PROGRAM

SELF-EVALUATION

Executive

Summary

During the

week of April 30,

1990,

NRC administered

Requal

Exams

were

given at Nine Mile Point Unit 2.

Fifteen individuals comprising three

control

room teams

were examined.

Results

are

as follows:

All three control

room

teams

were satisfactory.

Six of six

SROs

passed

the simulator

exam.

Nine of nine

ROs passed

the simulator

exam.

All fifteen operators

passed

the walkthrough

exam.

All fifteen operators

passed

the written exam.

All Program Evaluation Criteria that

can

be evaluated

by the facility

were satisfied.

More emphasis

is needed

on communications

during normal operations.

The

exam bank needs

to be

improved

in several

areas.

The program

has

shown significant

improvement

since

the

1989

exam

failure.

NRCU2/408

-1

May 1990

1.0

EXAM RESULTS

1.1

Individual

Exam Results

Note:

Fifteen operators

took the

exam.

Only fourteen

are

counted

for the program evaluation

since

one operator

was

a "retake"

candidate.

RO

Pass/Fail

SRO

Pass/Fail

TOTAL

Pass/Fail

WRITTEN

SIMULATOR

WALKTHROUGH

OVERALL

8/0

6/0

14/0

A more detailed

summary

by candidate

is attached.

Attachment

1 gives

the

grades for each

section of the

exam by candidate.

Attachment

2 is

a

matrix showing all

exam

items given to each

candidate.

1.2

Generic

Strengths

and

Weaknesses

Strengths

Use of Operating

Procedures

SSS control of the shift

Recognition or off normal

events prior to alarm

Alarm response

was timely with good action

Overall operator

task performance

Weaknesses

Communications

during normal operations

could

be

improved.

SSS did not always

inrorm the control

room shift of equipment

which had

been

"ec ared inoperable

Operators

did not always

ensure

that the

SSS

acknowledged

reports

SSS

had to ask for a parameter

and

then the parameter

trend

during emergency

events

Roles

are noi always clearly demonstrated

during emergencies

2.0 Program Evaluation

The Nine Mile Point Unit 2 Requal

Program

meets

the cri teria of ES-601

Rev.

5 as follows:

-2

May 1990

NRCU2/408

2.1

100'/. of the operators

passed

the

exam.

This exceeds

the

75'/

requirement of C.3.b.(1)(b).

2.2

The program meets

the requirements

of 10-CFR-55.59 (c)(2),(3)

and (4).

C.3.b. (1)(d)

2.3

One

common

JPM was failed by two of the fourteen operators. 'o other

common

JPM was failed by more

than

one operator.

This satisfies

the

criteria of C.3.b(2)(a).

2.4

No common

JPM question

was missed

by more than

one operator.

This

satisfies

the criteria of C.3.b(2)(b).

2.5

SROs

and

ROs

were rotated into all the licensed positions

they would

be expected

to fulfill at Nine Mile Point Unit 2.

This satisfies

the

criteria C.3.b.(2)(c).

2.6

Operators

were trained for in plant

JPMs satisfying

the criteria of

C.3.b.(2)(d).

2.7

100/ of the operators

answered

at least

80'/ of their

common

JPM

questions

correctly satisfying

the criteria of C.3,b.(2)(e).

2.8

A11 control

room crews

were satisfactory,

satisfying

the requirements

or O.l.c.(2)(c)4.

2.9

All operators

passed

the walkthrough

.exam satisfying

the requirement

of 0.2.c.(2)(b)(2).

2.10 All operators

passed

the written exam, satisfying

the -requirements

of

0.3.c.(2)(b).

3.0 Lessons

Learned

3.1

Exam Preparation

The following items

became

apparent

during the

exam process.

They

will be corrected

in preparing for our next exam.

The formality of exam preparation

needs

to improve.

Documentation

or the steps

in the process

needs

to be developed

and retained.

Exam questions

prepared

from industry events

need to reference

the event.

Job Performance

Measures

need questions

written to a higher

cognitive level.

Job Performance

Measures

need questions

unique to the

SRO

candidate.

NRCU2/408

Job Performance

Measures

could have

more than

two questions

to

allow evaluators

more flexibility.

-3

May 1990

/

ML17056A871

Text

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